Case Digest (G.R. No. 205727)
Facts:
Rutcher T. Dagasdas v. Grand Placement and General Services Corporation, G.R. No. 205727, January 18, 2017, First Division, Del Castillo, J., writing for the Court. Petitioner Rutcher T. Dagasdas (Dagasdas) filed an illegal dismissal complaint against respondent Grand Placement and General Services Corporation (GPGS), and its principal employers Industrial & Management Technology Methods Co. Ltd. (ITM) and Saudi Aramco (Aramco), after his repatriation from Saudi Arabia.In November 2007 GPGS, as recruitment agency for ITM, engaged Dagasdas for deployment to Saudi Arabia under a POEA‑approved contract as a Network Technician with a one‑year term and monthly salary of SR5,112.00. After arrival in Saudi Arabia on February 8, 2008, Dagasdas signed a second employment contract with ITM naming him Superintendent (with the same SR5,112.00 salary and SR2,045.00 allowance) and subjecting him to a three‑month probation; the contract purported to cancel prior agreements. Dagasdas alleged the Network Technician designation was merely a paper recruitment device and that he was in fact to serve as a Civil Engineering Superintendent; upon reporting to the site he was initially assigned Mechanical duties, later shifted to Civil Construction, but was then issued a termination notice effective April 30, 2008, invoking clause 17.4.3 that allowed termination during probation without notice. Before repatriation he executed a Statement of Quitclaim and Final Settlement acknowledging payment of SR7,156.80.
Dagasdas returned to the Philippines June 24, 2008 and filed suit for illegal dismissal, alleging misrepresentation, mismatch of work, lack of just cause and denial of due process. GPGS/ITM contended he accepted the superintendent post voluntarily, was a probationary employee properly terminated for poor performance, and validly executed the quitclaim.
The Labor Arbiter dismissed the complaint on November 27, 2009. On March 29, 2010 the National Labor Relations Commission (NLRC) reversed and found the dismissal illegal, ordering payment for the unexpired portion of the contract; the NLRC denied reconsideration on June 2, 2010. The Court of Appeals (CA), in CA‑G.R. SP...(Pro-only)
Issues:
- May the Supreme Court examine conflicting factual findings of inferior tribunals in a Rule 45 petition?
- Was Dagasdas validly dismissed from emp...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
- (Pro-only)